Thursday, January 11, 2018

Massaging the CFPB Complaint Database

I did not analyze this study by a student loan servicer, LendU in any great detail, I just wanted to reflect on one point - the miniscule rate of complaints filed in the CFPB consumer complaint database against the banks reviewed.

The CFPB has a consumer complaint database. If you have a complaint against a covered institution, you can register it there. The CFPB keeps all the complaints and claims to keep track of them in order to inform its rule-making. Needless to say,  the concept of a government agency keeping such a database is not without its critics.

Regardless, as shown in the above study, it would hardly seem to matter what the complaints say. The number of complaints-per-deposit account is miniscule. The worst 'offender' has 13.59 complaints per billion dollars of deposits.

This Deloitte review of CFPB complaints for 2012-2013 illustrates the problem. The highest number of mortgage complaints was in January 2013, 5,310. This figure is intriguing but compared to the number of currently existing mortgages, likely in the millions, it cannot be taken as indicative of much. It is difficult to see how such tiny samples could be seen as representative of anything.

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